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NFPA 3 2018 Cx Liability Issue

NFPA 3 2018 Cx Liability Issue

Quality, Consequences and the Construction Industrial Complex (part 193). 

Has anyone:

  • used, 
  • referenced, 
  • specified,
  • commissioned in accordance with;

“NFPA 3, Standard for Commissioning of Fire Protection and Life Safety Systems”?

It never ceases to amaze me how few building design, construction and commissioning professionals know that this standard exists. Even fewer people have actually used it as part of the building commissioning  process. 

During the recent CxEnergy 2019 conference ( ), a representative of NFPA gave a presentation on the forthcoming NFPA 3 2018: Standard for Commissioning of Fire Protection and Life Safety Systems.

The definition of commissioning contained in the draft standard has caused alarm:

“ Commissioning (Cx).

A systematic process that provides documented confirmation that building systems function according to the intended design criteria set forth in the project documents and satisfy the owner’s operational needs, including compliance with governing laws, regulations, codes, and standards. [Emphasis Added]”

Commissioning professionals are NOT responsible for code and regulatory compliance. They are not qualified nor paid for building code compliance. This USA / NFPA definition of commissioning “sets up the potential for both misunderstandings and conflicts, as well as serious liability and insurance concerns for commissioning firms”. (Quote source: Ray Bert, ACG Executive Director, April 2019). 

The conflation of building commissioning and code compliance consulting is an ongoing industry problem. In some Middle Eastern markets it is problematic as it leads to miss-selling of professional services that impact life safety. 

Shout out to the ACG Board. They are in action, and have prepared a comment to submit to NFPA calling attention to the problematic language. (Click here to view the substance of the ACG comment.)

The Public Comment period is open until May 8, 2019. Please support ACG and review the standard and make comments on this issue and any other areas where you have concerns. (Please click here to access the draft standard and make a public comment of your own.)

Twitter: @BLDWhisperer 

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#169 – Code Compliance is NOT Commissioning: 

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